Ergonomics Letter

February 26, 2001

Senator Gordon Smith
United States Senate
359 Dirksen Senate Office Bldg.
Washington, D.C. 20510

Dear Senator Smith,

The Oregon Neighborhood Store Association (ONSA) represents the smaller, mostly independently-owned grocery/convenience stores within the state of Oregon. ONSA's active membership consists of nearly 200 small corporations, which operate over 300 stores in the State. The full population of our Industry in Oregon is a very significant factor in the State's economy. In total there are over 2,600 independent Neighborhood Stores , which account for over $3 billion in annual sales, and their owners generate payments of nearly $500 million in payroll checks and various taxes each year. Oregon Neighborhood Stores provide employment, benefits and security for over 22,000 Oregonians. The majority of these small companies are family-owned.

ONSA members are seriously concerned with the Occupational Safety and Health Administration's (OSHA) ergonomic regulation. We understand Congress may vote on a Congressional Review Act joint resolution of disapproval, which would prevent the OSHA ergonomics rule from being implemented. ONSA strongly urges you to support such a resolution.

According to an economic study conducted by the National Association of Convenience Stores (NACS), the ergonomics rule could cost $20,000 per convenience store for the first year and an additional $4,700 for the next four years. In 1999, according to NACS' annual State of the Industry report the average store made a net profit of only $41,000. The projected costs of the ergonomics rule would represent nearly half of a store's net profit, and would spell the difference between survival and closure for many small, locally owned neighborhood stores.

ONSA members are concerned that many provisions, such as the single person trigger, won't work for our industry. Because our industry is a "first-employer", and in many cases the first entry on a young person's resume, the turnover rate is very high among entry-level employees. After learning basic job skills through our training, and gaining experience in our stores, many employees move on to companies which require a record of previous work experience. This fact makes the single person trigger and the record keeping requirements unworkable.

We also believe OSHA pursued the ergonomics rule without reliable scientific evidence to support the need for such a rule. A recently released National Academy of Sciences report concluded that none of the common musculoskeletal disorders are uniquely caused by work exposure. Further research is clearly needed before implementing a rule with such devastating effects for all types of businesses.

Within many small Oregon communities, our neighborhood stores provide a service, as well as employment. We urge you to support the resolution of disapproval. This action will send a message to OSHA, as well as other regulatory agencies, that regulations must be predicated on sound science, common sense, and realistic economics.

Thank you for your consideration.

Sincerely,

Chris Girard
Chairman of the Board, ONSA
Chairman of the Board, Plaid Pantries, Inc.